Short answer
There is currently no fixed, legally established date on which the digital product passport for tyres becomes mandatory. The underlying regulation (ESPR) mentions a work plan for the period 2025-2030, and it mentions a delegated act for tyres in 2027. Once that act is published, the exact implementation date will follow from it; based on current planning, around 2029 is expected, but this is not yet fixed. The implementation time that you yourself can influence is different: the time your own company needs to be ready once the obligation does come into effect.
This internal implementation time depends heavily on where you are in the supply chain and how many different tyre brands and models you stock. An importer with a handful of brands has a more straightforward process than a wholesaler with hundreds of article numbers from dozens of manufacturers. This article sets out what the phases are and where they typically run into delays in practice.
Two types of waiting time, not to be confused
It is useful to keep two things separate. The first is the legal deadline: when must the passport be in place. That deadline is not yet set and will be updated here once the delegated act is published. The second is the operational implementation time: how much time does it take to set up a working passport per product group, given the data you already have or can obtain. Companies that confuse these two often wait too long for the second because they think there is nothing to do until the first is fixed. In practice, a large part of the preparation can already start, even without a definitive date.
The phases a company typically goes through
A first phase is the inventory: which tyre types, brands and models do you stock, and who is the party responsible for providing the manufacturer or importer data for each. This sounds simple, but with a broad assortment and multiple suppliers, this alone takes several weeks, especially if data is scattered across different departments or locations.
Then comes the gathering of the source data itself: technical specifications, material information and the data that the manufacturer or importer is required to provide. This is often where the longest delay occurs, because not every manufacturer delivers as quickly or completely. A third phase is the choice of the system in which the passport is compiled and hosted, and the integration of that with your own purchasing and inventory management. Those who think through this integration carefully beforehand save themselves double work later. Finally, there is testing of the QR data carrier on the product or packaging, and informing the employees who will work with it in practice, for example when receiving goods or making sales.
Those who want to see how these phases come together in a concrete system can read about where the data for a passport comes from and how the integration with the QR code works in practice.
Where the implementation time in practice runs into problems
The most common delay occurs in companies with many different manufacturers or importers: each party provides data in a different format, at a different time and with different completeness. Without a fixed structure to organize that data, the collection phase easily stretches into months instead of weeks.
A second bottleneck is unclear roles in the supply chain. If it is not established who precisely acts as a supplier for a particular batch of tyres, delays occur because no one takes the initiative to complete the data. A third bottleneck is IT systems that do not interface with each other: an inventory system that does not communicate with the passport system means data is entered twice, with a greater chance of errors and more time per item.
A fourth, less technical bottleneck is postponement itself: because the definitive date is not yet established, some companies are also deferring their preparation. That is a choice each organisation makes for itself, but it does mean that the operational lead time only starts when the statutory deadline is already approaching.
What you can already do, irrespective of the end date
The inventory phase and the discussion with your software supplier about how data will be supplied later need not wait for the final regulations. The same applies to organising your records on manufacturer and importer data. Anyone wishing to see which topics are relevant for their own situation will find an orderly overview in the knowledge base with topics per situation. For your own position in the supply chain and the implications thereof, it remains advisable to consult a lawyer if in doubt or to consult the official text.
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